MEMORANDUM AND ORDER
HARRINGTON, District Judge.
This case arises from a citizen's action by Plaintiff, Natural Resources Defense Council, Inc., against Defendant, Gould, Inc., for at least one hundred sixty violations of the Clean Water Act, 86 Stat. 816, 33 U.S.C. § 1251 et seq. (1986 Ed.). Plaintiff alleges that one hundred fifty-seven of these violations occurred prior to filing the complaint on April 5, 1989, and at least three
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